ORB Basics - 11.1/2/3 - retention of sludge on board -

I assume you know the basics of writing an ORB entry.

We will talk about the figures for sludge, etc. later. But, first - what are the common items a PSCO looks for?

1) Entries for 11.1/ 2/ 3 (Retention of sludge on board)

You notice- it says sludge - not oily water (sludge has the consistency of mud, while oily water... obviously that of water). Obviously, entries would (or rather should) only refer to a tank which can contain sludge. Would you enter the sounding/ volume of, say.... a ballast tank here? Of course not! Bilges sounding - oh, no! A bilge tank here.... of course not.! An oily water settling tank? Naturally no! What a dumb question!!

Well, not so dumb really... this is the most common finding of Port state control inspectors.

Modus operandi -
Step 1 -

The PSCO checks which tanks are listed under the IOPP certificate under section 3.1 (Means for retention of oil residue - sludge). On this ship, there are 7 tanks.

Naturally, the bilge tank and bilge primary tank are NOT in 3.1, so they would NOT be entered in C-11.1/2/3... or should that have been "should not"?...

Step 2 -
The PSCO goes through ORB, and ... voila... there it is - Bilge tank has been wrongly entered under C-11.1/2/3...

So it was not so obvious , after all... eh? Now he looks for other entries of C-11.1/2/3 (lucky him - he gets that every week! or else - it is another mistake!) and finds the same repeated.

The above sounds like an innocent record keeping mistake - in reality it is not, as any maritime lawyer (esp. in USA) would tell you. It is an incorrectly kept oil record book - violates 33 CFR 151.25 and gives him grounds to further inspect your oily water separator, engine room, interview your crew, and basically, allow your stress levels and blood pressure to rise.

This is what the correct entry should have looked like....



But before that, the PSCO has already found a few more entries with the same mistake, like the one below....
... so there.

Did you notice an over-writing in the above entry... you didn't? Well the PSCO did!

Over-writing USCG Criminal Investigative division, in an important log book can make you look real bad - in front of the PSC, thethe EPA, the California Fish and game authority, the FBI (Oh yeah... they too have an environmental crimes division), your lawyer, and your judge (if you are unfortunate enough to land up there - which I sincerely hope you won't).

Why?

Well - it looks like you are trying to hide something. Even if you were not. So if you DO make a mistake, just strike it out, initial it (for eg: I would just write "O.R.B") and write the correct entry beside it.

So you see... finding mistakes in an ORB ain't no rocket science.

Make the entry the right way, next time.